This regulatory guide is being issued in draft form to involve the public in the early stages of the development of a regulatory position in this area. It hasnot received complete staff review or approval and does not represent an official NRC staff position.

Public comments are being solicited on this draft guide (including any implementation schedule) and its associated regulatory analysis or value/impactstatement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules and DirectivesBranch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Comments may be submitted electronically ordownloaded through the NRC’s interactive web site at <WWW.NRC.GOV> through Rulemaking. Copies of comments received may be examined at theNRC Public Document Room, 11555 Rockville Pike, Rockville, MD. Comments will be most helpful if received by March 9, 2004.

Requests for single copies of draft or active regulatory guides (which may be reproduced) or for placement on an automatic distribution list forsingle copies of future draft guides in specific divisions should be made to the U.S. Nuclear Regulatory Commission, Washington, DC 20555,Attention: Reproduction and Distribution Services Section, or by fax to (301)415-2289; or by email to DISTRIBUTION@NRC.GOV. Electroniccopies of this draft regulatory guide are available through the NRC’s interactive web site (see above); the NRC’s web site <WWW.NRC.GOV> inthe Electronic Reading Room under Document Collections, Regulatory Guides; and in the NRC’s ADAMS Documents at the same web site, underAccession Number ML033630447.

U.S. NUCLEAR REGULATORY COMMISSION December 2003 OFFICE OF NUCLEAR REGULATORY RESEARCH Division 7

DRAFT REGULATORY GUIDE

Contact: N.L. Osgood (301)415-8513

DRAFT REGULATORY GUIDE DG-7003(Proposed Revision 2 of Regulatory Guide 7.9)

STANDARD FORMAT AND CONTENT OF PART 71 APPLICATIONS FOR APPROVAL OF PACKAGING

FOR RADIOACTIVE MATERIAL

A. INTRODUCTION

This regulatory guide is being developed to provide guidance on the preparation ofapplications for approval of packaging to be used for the shipment of Type B and fissile radioactivematerial. It is not intended as an interpretation of the NRC’s regulations, within the meaning of 10CFR 71.2. Nothing contained in this guide is to be construed as having the force and effect of NRCregulations, or as indicating that applications supported by safety analyses and prepared inaccordance with the recommendations of this regulatory guide necessarily will be approved, or asrelieving any licensee from the requirements of 10 CFR Part 71, “Packaging and Transportation ofRadioactive Material,” or any other pertinent regulations.

This regulatory guide should not be considered a substitute for 10 CFR Part 71. Its primarypurpose is to assist the applicant in preparing an application that thoroughly and completelydemonstrates the adequacy of the package in meeting the regulations. In addition to a packageapproval, the applicant must have an approved quality assurance program in accordance with theprovisions of 10 CFR 71.101 through 71.137. Additional information may be requested in support ofan application if the NRC believes that such information is necessary to provide reasonableassurance of the safety of the proposed shipment. In preparing an application for package approval,the applicant may find it useful to refer to other regulatory guides in Division 7, “Transportation.”

Regulatory guides are issued to describe to the public methods acceptable to the NRC stafffor implementing specific parts of the NRC's regulations, to explain techniques used by the staff in

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evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations, and compliance with regulatory guides isnot required. Regulatory guides are issued in draft form for public comment to involve the publicin developing the regulatory positions. Draft regulatory guides have not received complete staffreview; they therefore do not represent official NRC staff positions.

The information collections contained in this draft regulatory guide are covered by therequirements of 10 CFR Part 71, which were approved by the Office of Management and Budget(OMB), approval number 3150-0008. The NRC may not conduct or sponsor, and a person is notrequired to respond to, a request for information or an information collection requirement unlessthe requesting document displays a currently valid OMB control number.

B. STANDARD FORMAT

Purpose of Standard Format

The purpose of this regulatory guide, “Standard Format and Content of Part 71Applications for Approval of Packaging for Radioactive Material” (hereinafter called “StandardFormat”), is to indicate the information to be provided in the application and to establish a uniformformat for presenting the information. Use of this format will help ensure the completeness of theinformation provided, will assist the NRC staff and others in locating the information, and will aidin shortening the time needed for the review process. The application is the principal documentin which the applicant provides the information and bases for the NRC staff to determine whetheror not the package meets the requirements of 10 CFR Part 71.

Applicability of Standard Format

This Standard Format applies specifically to applications for approval of package designsof Type B and fissile radioactive material under 10 CFR Part 71. The Standard Format identifiesgeneral and detailed information required and will help ensure the completeness of theinformation provided.

Use of Standard Format

The Standard Format presents a format for applications for approval that is acceptable tothe NRC staff. Conformance with the Standard Format, however, is not required. Applicationsfor approval with different formats will be acceptable to the NRC staff if they provide an adequatebasis for the findings requisite to the approval of packaging. However, because it may be moredifficult to locate needed information, the staff review time for such applications may be longer.

Upon receipt of an application, the NRC staff will perform a preliminary review todetermine whether the application provides a reasonably complete presentation of theinformation that is needed to form a basis for the findings required before approval of a packagein accordance with 10 CFR Part 71. The Standard Format will be used by the staff as a guidelineto identify the type of information needed. If the application does not provide a reasonablycomplete presentation of the necessary information, the application will not be reviewed furtheruntil a reasonably complete presentation is provided. The information provided in the applicationshould be up to date with respect to the state of technology for transportation of radioactivematerials and should take into account any recent changes in NRC regulations and guides,industry codes and standards, results of recent developments in transportation safety, andexperience in the construction and use of radioactive material packaging.

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Style and Composition

The applicant should strive for clear, concise presentation of the information provided inthe application. Confusing or ambiguous statements and unnecessarily verbose descriptions donot contribute to expeditious technical review. Claims of adequacy of designs or design methodsshould be supported by technical bases (i.e., by an appropriate engineering evaluation ordescription of actual tests). Terms as defined in the packaging and transport regulations must beused.

The application should follow the numbering system and headings of the StandardFormat at least to the headings with three digits (e.g., 2.1.2 Design Criteria). When a particularrequirement does not apply to a package, the corresponding subsection should not be omittedbut should be addressed with the term “Not Applicable.” A reason should be offered for notaddressing a particular requirement when there is doubt as to its applicability.

Appendices to each section of the application should include detailed information omittedfrom the main text. A list of reports or other documents that are referenced in the text of theapplication should be included in the appendix at the end of the section in which they arereferenced. When specific items are referenced, page numbers should be provided. Ifproprietary documents are referenced, the nonproprietary summary description of the documentshould also be referenced.

All physical tests of components and packages should be supported by photographs inthe appendices of the appropriate section. Appendices to the application may also be used toprovide supplemental information not explicitly identified in the Standard Format. Examples ofsuch information are (1) summaries of the manner in which the applicant has treated mattersaddressed in NRC regulatory guides and (2) supplementary information regarding calculationalmethods or design approaches used by the applicant.

When numerical values are stated, the number of significant figures given should reflectthe accuracy or precision to which the number is known. When possible, estimated limits of erroror uncertainty should be given. Significant figures should not be dropped or rounded off if, bydoing so, subsequent conclusions are inadequately supported.

Abbreviations should be consistent throughout the application and should be consistentwith generally accepted usage. Any abbreviations, symbols, or special terms unique to theproposed packaging or not in general usage should be defined in each section of the applicationin which they are used.

Drawings, diagrams, sketches, and charts should be used when the information can bepresented more accurately or conveniently by such means. Due concern should be taken toensure that all information presented in drawings is legible, symbols are defined, and drawingsare not reduced to the extent that visual aids are necessary to interpret pertinent items ofinformation presented in the drawings.

Pages should be numbered by section and sequentially within each section. Forexample, the fourth page of Section 6 would be numbered 6-4.

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Revisions

Data and text should be updated or revised by replacing pages. “Pen and ink” or “cut andpaste” changes should not be used.

The changed or revised portion on each page should be highlighted by a “changeindicator” mark consisting of a bold vertical line drawn in the margin opposite the binding margin. The line should be the same length as the portion actually changed.

All pages submitted to update, revise, or add pages to the application should show thedate of change and a change or amendment number. A transmittal letter, including a guide pagelisting the pages to be inserted and the pages to be removed, should accompany the revisedpages. When applicable, supplemental pages may follow the revised page.

All statements on a revised page should be accurate as of the date of the submittals.

Special care should be taken to ensure that the main sections of the application arerevised to reflect any design changes reported in supplemental information (i.e., responses toNRC staff requests for information or responses to regulatory positions).

Physical Specifications

All material submitted as part of the application should conform to specific standards as tothe physical dimensions of page size, quality of paper and inks, and numbering of pages,exhibits, and attachments. More specifically:

Paper Size (not to exceed) Text pages: 8 ½ × 11 inches.Drawings and graphics: 8 ½ × 11 inches preferred; however, a larger size is acceptable

provided:

a. After reduction, the size does not exceed 11 × 17 inches, including a 2-inchmargin at left for binding.

b. The finished copy when folded does not exceed 8 ½ × 11 inches.

All drawings should have a drawing number, sheet number, company name, title, revisionnumber, date of revision, and signature or initials indicating approval of the drawing and eachrevision.

Paper Stock

Weight or substance: 20 pound for printing on both sides.16 to 20 pound for printing on one side only.

Composition: Wood chemical sulfite (no groundwood) and a pH of 5.5.

Color: White is preferred, but pastel colors are acceptable providedthe combination of paper stock and ink is suitable formicrofilming.

Ink: Color sufficiently dense to record on microfilm or image-copying equipment.

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Page Margins: A margin of no less than 1 inch should be maintained on the top, bottom, andbinding side of all pages.

Printing

Composition: Text pages should be single spaced.

Type font and style: Must be suitable for microfilming.

Reproduction: May be mechanically or photographically reproduced. Text pagesshould preferably be printed on two sides with the image printedhead to head.

Binding: Pages should be punched for standard 3-hole looseleaf binder and containedwithin a binder supplied by the applicant.

Separators: Separators should be provided between each section of the application.

Number of Copies: Ten copies of the application should be provided.

Proprietary Withholding

Proprietary information, such as specific design details shown on the engineeringdrawings, may be withheld from public disclosure subject to the provisions of 10 CFR 2.790. Therequest for withholding must be accompanied by an affidavit and must include information tosupport the claim that the material is proprietary. Requests for withholding are reviewed by theNRC’s Office of the General Counsel for compliance with the requirements of 10 CFR 2.790.

C. APPLICATIONS

1. GENERAL INFORMATION

This section of the application should present an introduction and a description of thegeneral package.

1.1 INTRODUCTION

This section should include the proposed use of the package, the model number, and, inthe case of fissile packages, the proposed Criticality Safety Index (CSI).

1.2 PACKAGE DESCRIPTION

1.2.1 Packaging The general packaging description should include:

• The overall dimensions, maximum weight (fully loaded), and minimum (empty)weight (if appropriate)

• Containment features • Neutron and gamma shielding features, including personnel barriers

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• Criticality control features, including neutron poisons, moderators, and spacers• Structural features, including lifting and tie-down devices, impact limiters or other

energy-absorbing features, internal supporting or positioning features, outer shellor outer packaging, and packaging closure devices

• Heat transfer features• Packaging markings.

1.2.2 Containment SystemThe containment system components should be clearly identified. The exact boundary of

the containment system should be defined; this may include the containment vessel, welds, drainor fill ports, valves, seals, test ports, pressure relief devices, lids, cover plates, and other closuredevices. If multiple seals are used for a single closure, the seal defined as the containment-system seal should be clearly identified. A sketch of the containment system should be provided. All components should be shown on the engineering drawings in the appendix.

1.2.3 ContentsState the quantity of radionuclides to be transported. Describe the contents in the same

detail as intended for the certificate of compliance. The description should include, if appropriate,the following information:

• Identification and maximum quantity (radioactivity or mass) of the radioactivematerial

• Identification and maximum quantity of fissile material• Chemical and physical form, including density and moisture content, and the

presence of any moderating constituents• Location and configuration of contents within the packaging, including secondary

containers, wrapping, shoring, and other material not defined as part of thepackaging

• Identification and quantity of nonfissile materials used as neutron absorbers ormoderators

• Any material subject to chemical, galvanic, or other reaction, including thegeneration of gases

• Maximum weight, and minimum weight if appropriate• Maximum decay heat• Any loading restrictions.

1.2.4 Operational FeaturesIn the case of a complex package system, discuss the operational features of the

package. This should include a schematic diagram showing all valves, connections, piping,openings, seals, containment boundaries, etc.

1.3 GENERAL REQUIREMENTS FOR ALL PACKAGES

The package description should address the requirements of 10 CFR 71.43, “GeneralStandards for All Packages.”

1.3.1 Minimum Package SizeThe smallest overall dimension of the package should not be less than 10 cm (4 in).

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1.3.2 Tamper-Indicating FeatureDescribe and discuss the package closure system in sufficient detail to show that it

incorporates a protective feature that, while intact, is evidence that the package has not beentampered with by unauthorized persons. This discussion should include covers, ports, or otheraccess that must be closed during normal transportation. Describe tamper indicators and theirlocations.

1.4 APPENDIX

Drawings that clearly detail the safety features considered in the analysis should beincluded in Appendix 1.3. The drawings should include a materials list, dimensions, valves,fasteners, and welder and welding procedure qualification requirements. The drawings shouldspecify, by appropriate weld symbol, the specifications for all packaging weld joints, including themethod of nondestructive examination and the acceptance standard. Gasketed joints in thecontainment system should be sufficiently detailed to show, as a minimum, the surface finish andflatness requirements of the closure surfaces, the gasket or O-ring specification, and, ifappropriate, the method of gasket or O-ring retention. Detailed construction drawings of large,complex packages should not be included. Packages authorized for shipment must conform tothe approved design, that is, packages must conform to the drawings specified in the NRCapproval.

The appendix should also include a list of references, a copy of any applicable referencenot generally available, supporting information on special fabrication procedures, determinationof the package category, and other appropriate supplemental information.

2. STRUCTURAL EVALUATION

This section of the application should identify, describe, discuss, and analyze the principalstructural design of the packaging, components, and systems important to safety and describehow the package complies with the performance requirements of 10 CFR Part 71.

2.1 DESCRIPTION OF STRUCTURAL DESIGN

2.1.1 Discussion

Identify the principal structural members and systems such as the containment vessel,impact limiters, radiation shielding, closure devices, and ports that are important to the safeoperation of the package. Reference the location of these items on drawings and discuss theirstructural design and performance.

Descriptive information important to structures includes:

• Dimensions, tolerances, and materials• Maximum and minimum weights and centers of gravity of packaging and major

subassemblies• Maximum and minimum weight of contents, if appropriate• Maximum normal operating pressure• Description of closure system• Description of handling requirements• Fabrication methods, as appropriate.

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2.1.2 Design CriteriaDescribe the load combinations and factors that serve as design criteria. Design criteria

may be used if judged acceptable by the NRC staff in meeting the structural requirements of10 CFR 71.41 through 71.51. For each of these criteria, state the maximum allowable stressesand strains (as a percentage of the yield or ultimate values for ductile failure); describe how theother structural failure modes (e.g., brittle fracture, fatigue, buckling) are considered. If differentdesign criteria are to be allowed in various parts of the packaging or for different conditions, theappropriate values for each case should be indicated. Include the criteria that will be used forimpact evaluation. Identify all codes and standards that are used to determine materialproperties, design limits, or methods of combining loads and stresses. In cases of deviation fromstandard codes, or if certain components are not covered by such codes, provide a detaileddescription of the design criteria used as substitutes.

2.1.3 Weights and Centers of GravityList the total weight of the packaging and contents. Tabulate the weights of major

individual subassemblies such that the sum of the parts equals the total of the package. Locatethe center of gravity of the package and any other centers of gravity referred to in the application. It is not necessary to include the calculations made to determine these values, but a sketch ordrawing that clearly shows the individual subassembly referred to and the reference point forlocating its center of gravity should be included.

2.1.4 Identification of Codes and Standards for Package DesignIdentify the established codes and standards proposed for use in package design,

fabrication, assembly, testing, maintenance and use. Include an assessment of the applicabilityof the codes and standards. The codes or standards proposed should be appropriate for thepackage category (see Table 2-1).

Table 2-1 Category Designations for Type B Packages (from Regulatory Guide 7.11)

Contents Form/Category

Category I Category II Category III

Special Form Greater than 3,000A1* or greater than 1.11PBq (30,000 Ci)

Between 3,000 A1* and 30A1*, and not greater than1.11 PBq (30,000 Ci)

Less than 30 A1* andless than 1.11 PBq(30,000 Ci)

Normal Form Greater than 3,000A2* or greater than1.11 PBq (30,000 Ci)

Between 3,000 A2* and 30A2*, and not greater than1.11 PBq (30,000 Ci)

Less than 30 A2* andless than 1.11 PBq(30,000 Ci)

* A1 and A2 are defined in 10 CFR 71.4.

2.2 MATERIALS

2.2.1 Material Properties and SpecificationsList the material mechanical properties used in the structural evaluation. This may

include yield stress, ultimate stress, modulus of elasticity, ultimate strain, Poisson’s ratio, density,and coefficient of thermal expansion. If impact limiters are used, include either a compressionstress-strain curve for the material or the force-deformation relationship for the limiter, asappropriate. For materials subjected to elevated temperatures, the appropriate mechanical

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properties under these conditions should be specified. The source of all information in thissection should be clearly and specifically referenced as to publication and page number. Wherematerial properties are determined by testing, the test procedure, conditions, and measurementsshould be described in sufficient detail to allow the staff to conclude that the results are valid.

2.2.2 Chemical, Galvanic, or Other ReactionsDiscuss possible chemical, galvanic, or other reactions in the packaging or between the

packaging and the package contents, as well as methods used to prevent significant reactions. For each component material of the packaging, list all chemically or galvanically dissimilarmaterials with which it has contact. Coatings used on internal or external package surfacesshould be considered. Consider reactions resulting from water inleakage or cask flooding andtake into consideration the possible generation of hydrogen or other gases from chemical orradiolytic interactions. Galvanic interactions and the formation of a eutectic should be consideredfor components that are or may be in physical contact.

2.2.3 Effects of Radiation on MaterialsDescribe any aging or damaging effects of radiation on the packaging materials. These

effects may include degradation of seals, sealing materials, coatings, adhesives, and structuralmaterials.

2.3 FABRICATION AND EXAMINATION

2.3.1 FabricationDescribe the fabrication processes used for the package, such as fitting, aligning, welding

and brazing, heat treatment, and foam and lead pouring. For fabrication specificationsprescribed by an acceptable code or standard (e.g., ASME, AWS), the code or standard shouldbe identified on the engineering drawings. Unless the application justifies otherwise,specifications of the same code or standard used for design should also be used for fabrication. For components for which no code or standard is applicable, the application should identify thespecifications on which the evaluation depends and describe the method of control to assure thatthese specifications are achieved. This description may reference a quality assurance or otherappropriate specifications document, which should be specified on the engineering drawings.

2.3.2 ExaminationExamination addresses the methods and criteria by which the fabrication is determined to

be acceptable. Unless the application justifies otherwise, specifications of the same code orstandard used for fabrication should also be used for examination. For components for which nofabrication code or standard is applicable, the application should summarize the examinationmethods and acceptance criteria in Section 8, "Acceptance Tests and Maintenance Program."

2.4 LIFTING AND TIE-DOWN STANDARDS FOR ALL PACKAGES

2.4.1 Lifting DevicesIdentify all devices and attachments that can be used to lift the package or its lid. Show by

testing or analysis that these devices comply with the requirements of 10 CFR 71.45(a). Providedrawings or sketches that show the location and construction of these items. Determine theeffects of the forces imposed by lifting device and other packaging surfaces. Documentedvalues of the yield stresses of the materials should be used as the criteria to demonstratecompliance with 10 CFR 71.45(a), including failure under excessive load.

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2.4.2 Tie-Down DevicesIdentify all devices that are a structural part of the package and can be used as tie-

downs. Discuss the overall tie-down system. Show by testing or analysis that these devicescomply with the requirements of 10 CFR 71.45(b). Provide drawings or sketches that show thelocation and construction of these devices and the overall tie-down system. Determine the effectof the imposed forces of vital package components, including the interfaces between the tie-down devices and other package surfaces. Documented values of the yield stresses of thematerials should be used as the criteria to demonstrate compliance with 10 CFR 71.45(b),including failure under excessive load.

2.5 GENERAL CONSIDERATIONS

Package structural evaluation may be performed by analysis or test or a combination ofboth. In describing the structural evaluation of package, clearly show that the most limiting initialtest conditions and most damaging orientations are considered, and the evaluation methods areappropriate and properly applied.

2.5.1 Evaluation by TestDescribe the test method, procedures, equipment, and facilities that were used. Describe

the package orientations for free drop, puncture and immersion tests. If the package tested isnot identical in all respects to the package described in the application, explain the differencesand show that these differences would not affect the test results.

Describe the materials used as substitutes for the radioactive contents during the tests. Show that this substitution would not affect the test results. Consider the effects of internaldecay heat and pressure buildup if these effects would have arisen with the actual loading.

Describe in a quantitative manner the damage caused by the tests and the results of anymeasurements that were made. Include both interior and exterior damage. Provide photographsof the damaged packaging.

For prototype and model testing, describe the test specimen completely and providedetailed drawings that show its dimensions and materials of construction. Specify thedimensional tolerances to which the prototype or model was fabricated and compare these to thetolerances that will be used for the package.

For scale models, state the scale factor that was used. Describe in detail the laws ofsimilitude that were used for testing, considering time scale, material density, velocity at impact,and kinetic energy. Show that the model test will give conservative results for peak g-force,maximum deformation, and dissipated energy. Correlate the damage done to the model withdamage to the package and show that the package would be adequate to meet the performancerequirements of 10 CFR Part 71.

2.5.2 Evaluation by AnalysisDescribe the methods and calculations used in the package evaluation in sufficient detail

to allow the results to be verified. Clearly describe and justify all assumptions that are used inthe analysis. Include adequate narration and use of sketches and free body force diagrams. Forequations used in the analysis, either the source should be referenced or the derivation shouldbe included.

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For computer analyses, including finite element analyses, describe the computer programand show that it is well benchmarked, widely used for structural analyses, and applicable to theevaluation. Clearly describe any models and modeling details. The number of discrete finiteelements used in the model should reflect the type of analysis being performed. For example,regions in the model of high stress or displacement should have a higher number of elementsthan regions that have a nearly equilibrated state of stress or are in a uniform stress field. Describe sensitivity studies used to determine the appropriate number of nodes or elements for aparticular model. Describe in detail the modeling of bolted connections, including element types,modeling technique, and material properties.

The analysis should show how all the kinetic energy will be dissipated and what localdeformation and dynamic forces occur during impact. The response of the package in terms ofstress and strain to components and structural members should be shown. The structuralstability of individual members, as applicable, should be investigated as well as stress that is dueto impact combined with those stresses caused by temperature gradients, differential thermalexpansions, pressure, and other loads. Provide a direct comparison of the results of the analysiswith the acceptance criteria and show that the performance requirements of 10 CFR Part 71 aremet.

2.6 NORMAL CONDITIONS OF TRANSPORT

In this section, show that the package, when subjected to the conditions and test (normalconditions of transport) specified in 10 CFR 71.71, meets the standards specified in10 CFR 71.43 and 71.51, as demonstrated in the following paragraphs. The package should beassessed against each condition separately and a determination made that the applicableperformance requirements specified in the regulations have been satisfied.

2.6.1 HeatThe thermal evaluation for the heat test should be described and reported in Section 3,

"Thermal Evaluation."

2.6.1.1 Summary of Pressures and Temperatures. Summarize all pressures andtemperatures determined in Section 3, "Thermal Evaluation," that will be used to perform thecalculations required for Sections 2.6.1.2, 2.6.1.3, and 2.6.1.4.

2.6.1.2 Differential Thermal Expansion. Calculate the circumferential and axialdeformations and stresses (if any) that result from differential thermal expansion. Considersteady-state and transient conditions. These calculations must be sufficiently comprehensive todemonstrate package integrity under normal transport conditions.

2.6.1.3 Stress Calculations. Calculate the stresses that are due to the combinedeffects of thermal gradients, pressure, and mechanical loads (including fabrication stresses fromlead pour and lead cooldown). Provide sketches that show the configuration and dimensions ofthe members or systems being analyzed and locate the points at which the stresses are beingcalculated. The analysis should consider whether repeated cycles of thermal loadings, togetherwith other loadings, will cause fatigue failure or extensive accumulations of deformation.

2.6.1.4 Comparison with Allowable Stresses. Make the appropriate stresscombinations and compare the resulting stresses with the design criteria specified in theapplication. Show that all the performance requirements specified in the regulations have beensatisfied.

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2.6.2 ColdThe thermal evaluation under cold conditions should be described and reported in

Section 3, "Thermal Evaluation." Assess the package for the effects of the cold condition,including material properties and possible freezing of liquids and lead shrinkage. Identify, forsafety components, the resulting temperatures and their effect on operation of the package. Brittle fracture should be considered. Stresses should be within the limits for normal conditionloads. For the sequential hypothetical accident test series, -29oC (-20oF) is the lowest servicetemperature that needs to be considered, as specified in 10 CFR 71.73(b).

2.6.3 Reduced External PressureAssess the package design for the effects of reduced external pressure specified in 10

CFR 71.71(c). Calculate the greatest possible pressure difference between the inside andoutside of the package as well as the inside and outside of the containment system. Evaluatethis condition in combination with the maximum normal operating pressure.

2.6.4 Increased External PressureAssess the package design for the effects of increased external pressure as specified in

10 CFR 71.71(c). Evaluate this condition in combination with minimum internal pressure.Calculate the greatest possible pressure difference between the inside and outside of thepackage as well as the inside and outside of the containment system. Calculate the possibility ofbuckling.

2.6.5 VibrationAssess the package for the effects of vibrations normally incident to transport.

Investigate the combined stresses due to vibration, temperature, and pressure loads and providea fatigue analysis, if necessary. If closure bolts are reused, include bolt preload in the fatigueevaluation. Check packaging components for resonant vibration conditions that can cause rapidfatigue damage. The effect on package internals should also be considered.

2.6.6 Water SprayAssess the package design for the effects of the water spray test. Ensure that this test

has no significant effect on material properties.

2.6.7 Free DropAssess the package for the effects of the free drop test. The general comments in

Section 2.7.1 also apply to this condition. Note that the free drop test follows the water spraytest. Address such factors as drop orientation, effects of free drop in combination with pressure,heat, and cold temperatures, and other factors discussed in Section 2.5.

2.6.8 Corner DropIf applicable, describe the effects of corner drops on the package.

2.6.9 CompressionFor packages weighing up to 5,000 kg (11,000 lbs), describe the effects of compression

on the package.

2.6.10 PenetrationDescribe the effects of penetration on the package. Note that the point of impact could

be at any location on the exterior surface of the package. Indicate which package location ismost vulnerable.

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2.7 HYPOTHETICAL ACCIDENT CONDITIONS

In this section, show that the package, when subjected to the tests (hypothetical accidentconditions) as specified in 10 CFR 71.73, meets the standards specified in 10 CFR 71.51,71.55(e) and 71.59(a)(2), as demonstrated in the following paragraphs.

Consider the hypothetical accident conditions specified by the regulations in 10 CFR71.73, in the order indicated, to determine their cumulative effect on a package. Damage causedby each test is cumulative, and the evaluation of the ability of a package to withstand any onetest must consider the damage that resulted from the previous tests. It should be noted that adetermination must have been made in Section 2.6 that the effectiveness of the package has notbeen reduced as a result of the normal conditions of transport. Brittle fracture should beconsidered.

2.7.1 Free DropThe performance and structural integrity of a package must be evaluated for the drop

orientation that causes the most severe damage, including center-of-gravity-over-corner, obliqueorientation with secondary impact (slap down), side drop, and drop onto the closure. Anorientation that results in the most damage to one system or component may not be the mostdamaging for other systems and components. If a feature such as a tie-down component is astructural part of the package, it should be considered in the selection of the drop testconfigurations and the drop orientation. For these reasons, it is usually necessary to considerseveral drop orientations. Orientations for which the center of gravity is directly over the point ofimpact must be considered.

Assess a package with lead shielding for the effects of lead slump. The lead slumpdetermined should be consistent with that used in the shielding evaluation.

Assess the closure lid bolt design for the combined effects of free drop impact force,internal pressures, thermal stress, O-ring compression force, and bolt preload.

Assess other package components, such as port covers, port cover plates, and shieldenclosures, for the combined effects of package drop impact force, puncture, internal pressures,and thermal stress.

Consider the buckling of package components.

The assessment of the package may be by analysis, prototype testing, model testing, orcomparison to a similar package.

2.7.1.1 End Drop. Describe the effects of the end drop test on the package.

2.7.1.2 Side Drop. Describe the effects of the side drop test on the package.

2.7.1.3 Corner Drop. Describe the effects of the corner drop test on the package.

2.7.1.4 Oblique Drops. Assess the package for the effects of oblique drops orprovide information that shows that the end, side, and corner drops are more damaging to allsystems and components vital to safety.

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2.7.1.5 Summary of Results. Discuss the condition of the package after each droptest. Summarize the extent to which the packaging would be damaged in each orientation.

2.7.2 CrushIf applicable, describe the effects of the dynamic crush test on the package.

2.7.3 PunctureDescribe the effects of puncture on the package. Identify and justify that the position for

which maximum damage would be expected has been evaluated. Any damage resulting fromthe free drop and crush tests must be considered. Consider both local damage near the point ofimpact of the puncture bar and the overall effect on the package. Note that the point of impactcould be at any location on the exterior surface of the package. It is particularly important that allvalves and fittings necessary for containment be considered. General comments provided inSections 2.5 and 2.7.1 may also apply to this test condition.

Although analytical methods are available for predicting puncture, empirical formulasderived from puncture test results of laminated panels are usually used for the design ofpackages. The Nelm’s formula developed specifically for package design provides the minimumthickness needed for preventing the puncture of the steel surface layer of a typical steel-lead-steel laminated cask wall.

Consider punctures at oblique angles, near a support, at a valve, at the package closure,and at a penetration as appropriate.

2.7.4 ThermalThe thermal test should follow the free drop test and puncture tests and should be

reported in Section 3, "Thermal Evaluation." Evaluate the structural design for the effects of afully engulfing fire, as specified in 10 CFR 71.73(c)(4). Any damage resulting from the free drop,crush, and puncture conditions must be incorporated into the initial condition of the package forthe fire test. Consider the temperatures resulting from the fire and any increase in gas inventorycaused by combustion or decomposition processes when determining the maximum pressure inthe package during or after the test. Assess the maximum thermal stresses, which can occureither during or after the fire.

2.7.4.1 Summary of Pressures and Temperatures. Summarize all thetemperatures and pressures, as determined in Section 3, "Thermal Evaluation," of theapplication.

2.7.4.2 Differential Thermal Expansion. Calculate the circumferential and axialdeformations and stresses (if any) that result from differential thermal expansion. Consider peakconditions, postfire steady-state conditions, and all transient conditions.

2.7.4.3 Stress Calculations. Calculate the stresses caused by thermal gradients,differential expansion, pressure, and other mechanical loads. Provide sketches showingconfiguration and dimensions of the members of systems under investigation, and locate thepoints at which the stresses are being calculated.

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2.7.4.4 Comparison with Allowable Stresses. Make the appropriate stresscombinations and compare the resulting stresses with the design criteria in Section 2.1.2 of theapplication. Show that all the performance requirements specified in the regulations have beensatisfied.

2.7.5 Immersion – Fissile MaterialIf the contents include fissile material subject to the requirements of 10 CFR 71.55, and if

water leakage has not been assumed for the criticality analysis, assess the effects andconsequences of the water immersion test condition by immersing a damaged specimen under ahead of water of at least 0.9 m (3 ft.) in the orientation for which maximum leakage is expected.

2.7.6 Immersion – All PackagesEvaluate an undamaged package for water pressure equivalent to immersion under a

head of water of at least 15 m (50 ft.) for 8 hours. For test purposes, an external gauge pressureof water of 150 kPa (21.7 psi) gauge is considered to meet these conditions.

2.7.7 Deep Water Immersion Test (for Type B Packages Containing More than105 A2)

If applicable, evaluate the package for an external water pressure of 2 MPa (290 psi) for aperiod of no less than one hour, in accordance with 10 CFR 71.61.

2.7.8 Summary of DamageDiscuss the condition of the package after the accident test sequences. Summarize the

extent to which safety systems and components have been damaged and relate the packagecondition to the acceptance standards.

2.8 ACCIDENT CONDITIONS FOR AIR TRANSPORT OF PLUTONIUM

If applicable, address the accident conditions specified in 10 CFR 71.74.

2.9 ACCIDENT CONDITIONS FOR FISSILE MATERIAL PACKAGES FOR AIRTRANSPORT

If applicable, address the accident conditions specified in 10 CFR 71.55(f).

2.10 SPECIAL FORM

As applicable when special form is claimed, state that the contents meet special formrequirements given in 10 CFR 71.75 when subjected to the applicable test conditions of 10 CFR71.77. Describe the chemical and physical form. If the source is not a doubly encapsulated rightcircular cylinder of welded construction, provide a detailed drawing of the encapsulation showingthe dimensions, materials, manner of construction, and method of nondestructive examination.

2.11 FUEL RODS

In Section 4, “Containment,” where fuel rod cladding is considered to provide containmentof radioactive material under normal or accident test conditions, provide an analysis or testresults showing that the cladding will maintain sufficient mechanical integrity to provide thedegree of containment claimed.

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2.12 APPENDIX

The appendix should include a list of references, copies of applicable references if notgenerally available, computer code descriptions, input and output files, test results, test reports,and other appropriate supplemental information.

3. THERMAL EVALUATION

This section of the application should identify, describe, discuss, and analyze the principalthermal engineering design of the packaging, components, and systems important to safety anddescribe how the package complies with the performance requirements of 10 CFR Part 71.

3.1 DESCRIPTION OF THERMAL DESIGN

Describe the significant thermal design features and operating characteristics of thepackage. The operation of all subsystems should be discussed. Identify any thermal criteria thatwill be applied directly to thermal results (e.g., maximum fuel temperature, shield temperature notto exceed melt). Also identify properties evaluated here but used to support other evaluations(e.g., pressure, temperature, distributions relative to thermal stress). Summarize the significantresults of the thermal analysis or tests and the implication of these results on the overallpackage. State the minimum and maximum decay heat loads assumed in thermal evaluation. The maximum decay heat load assumed should be consistent with the source terms assumed inthe shielding and containment analyses.

3.1.1 Design FeaturesDesign features important to thermal performance include:

• Package geometry and materials of construction.• The structural and mechanical features that may affect heat transfer, such as

cooling fins, insulating materials, surface conditions of the package components,and gaps or physical contacts between internal components.

3.1.2 Content’s Decay HeatThe maximum decay heat and the radioactivity of the contents should be specified. Show

that the decay heat is consistent with the maximum quantity of radioactive contents.

3.1.3 Summary Tables of TemperaturesPresent summary tables of the maximum or minimum temperatures that affect structural

integrity, containment, shielding, and criticality for both normal conditions of transport andhypothetical accident conditions. For the fire test condition, the tables should also include:

• The maximum temperatures of various package components and the time atwhich they occur after fire initiation.

• The maximum temperatures of the post-fire steady-state condition.

3.1.4 Summary Tables of Maximum PressuresInclude the maximum normal operating pressure and maximum pressure under

hypothetical accident conditions in the summary tables.

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3.2 MATERIAL PROPERTIES AND COMPONENT SPECIFICATIONS

3.2.1 Material PropertiesSpecify the appropriate thermal properties for materials that affect heat transfer both

within the package and from the package to the environment. Include any liquids or gases withinthe package and gases external to the package for hypothetical accident conditions. Thethermal absorptivities and emissivities should be appropriate for the package surface conditionsand each thermal condition. When reporting a property as a single value, ensure that this valuebounds the equivalent temperature-dependent property. References for the data cited should beprovided.

3.2.2 Component SpecificationsInclude the technical specifications of package components, as appropriate. For

example, in the case of valves or seals, the operating pressure range and temperature limitsshould be included. The properties of fabricated insulation and coatings should be tabulated. Test data should be supplied in support of performance specifications and should be presentedin detail in the appendix. Specify the maximum allowable service temperatures or pressures foreach package component, as appropriate. The minimum allowable service temperature of allcomponents should be less than or equal to -40°C (-40 °F).

3.3 GENERAL CONSIDERATIONS

Thermal evaluations of the package design can be performed by analysis or test or by acombination of both.

3.3.1 Evaluation by AnalysisDescribe the methods and calculations used in the package thermal evaluation in

sufficient detail to allow the results to be verified. Clearly describe and justify all assumptionsthat are used in the analysis. For computer analyses, including finite element analyses, describethe computer program and show that it is well benchmarked and widely used for thermalanalyses and is applicable to the evaluation. Clearly describe any models and modeling details.

3.3.2 Evaluation by TestDescribe the test method, procedures, equipment, and facilities that were used. If the

package tested is not identical in all respects to the package described in the application, explainthe differences and show that these differences would not affect the test results. Temperaturedata should be taken at gaskets, valves, and other containment boundaries, as well as for theoverall package, especially temperature-sensitive materials.

Some conditions, such as ambient temperature, decay heat of the contents, or packageemissivity or absorptivity, may not be exactly represented in a thermal test. Include appropriatecorrections or evaluations to account for these differences.

Describe in a quantitative manner the damage caused by the tests and the results of anymeasurements that were made. Include both interior and exterior temperatures. Providephotographs of the testing and the test specimen.

3.3.3 Margins of SafetyAppropriately address the margins of safety for package temperatures, pressures, and

thermal stresses. Include the effects of uncertainties in thermal properties, test conditions and

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diagnostics, and analytical methods. Show that the analysis or test results are reliable andrepeatable.

3.4 THERMAL EVALUATION UNDER NORMAL CONDITIONS OF TRANSPORT

Evaluate the package performance, including system and subsystem operation, fornormal conditions of transport with respect to the results of the thermal analysis or testsperformed. Take into account significant conditions to be found in the ranges bounded by theminimum and maximum ambient temperatures and minimum and maximum decay heat loads. Compare the results with allowable limits of temperature, pressure, etc., for the packagecomponents. Designate the information that is to be used in other sections of the review. Present the information in summary tables along with statements and appropriate comments.

3.4.1 Heat and ColdDemonstrate that the tests for normal conditions of transport do not result in significant

reduction in packaging effectiveness, including:

• Degradation of the heat-transfer capability of the packaging (such as creation ofnew gaps between components),

• Changes in material conditions or properties (e.g., expansion, contraction, gasgeneration, and thermal stresses) that affect the structural performance,

• Changes in the packaging that affect containment, shielding, or criticality such asthermal decomposition or melting of materials,

• Ability of the packaging to withstand the tests under hypothetical accidentconditions.

Verify that the component temperatures and pressures do not exceed their allowablevalues. Show that the package meets the maximum surface temperature requirements specifiedin 10 CFR 71.43(g).

3.4.2 Maximum Normal Operating PressureDetermine the maximum normal operating pressure when the package has been

subjected to the heat condition for one year. In regard to the maximum normal operatingpressure calculation, consider all possible sources of gases such as:

• Gases initially present in package• Saturated vapor, including water vapor from the contents or packaging.• Helium from the radioactive decay of the contents• Hydrogen or other gases resulting from thermal- or radiation-induced

decomposition of materials such as water or plastics• Fuel rod failure.

Demonstrate that hydrogen and other flammable gases will not result in a flammablemixture within any confined volume.

3.4.3 Maximum Thermal StressesDetermine the most severe thermal stress conditions that result during the fire test and

subsequent cool-down. Report the temperatures corresponding to the maximum thermalstresses.

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3.5 THERMAL EVALUATION UNDER HYPOTHETICAL ACCIDENT CONDITIONS

Evaluate the package performance under hypothetical accident thermal conditions. Thehypothetical accident conditions as defined in 10 CFR 71.73, are applied sequentially.

3.5.1 Initial ConditionsPrior to the fire test, consider the effects of the drop, crush (if applicable), and puncture

tests on the package design. Identify and justify the initial conditions that are most unfavorable,including initial ambient temperature, internal pressure, decay heat, etc.

3.5.2 Fire Test ConditionsDescribe in detail the test or analyses used to evaluate the package under the fire test

conditions. Show that the evaluation addresses the requirements in 10 CFR 71.73(c).

3.5.3 Maximum Temperatures and PressureDetermine the transient peak temperatures of package components, as a function of time

both during and after the fire. Determine the maximum temperatures from the post-fire, steady-state condition. The transient results of the thermal analysis or test should be presented. Thetemperatures reported should include those temperatures at locations in the package that aresignificant to the safety analysis and review. Report the temperatures for such items ascontents, gaskets, valves, and shielding. The calculations of transient temperatures should tracethe temperature-time history up to and past the time at which temperature maximums areachieved and begin to fall.

Base the evaluation of the maximum pressure in the package design on the maximumnormal operating pressure as it is affected by fire-caused increases in package componenttemperatures. Account for possible increases in pressure caused by fire-induced thermalcombustion or decomposition processes, fuel rod failure, phase changes, etc.

Compare the results with allowable limits of temperature, pressure, etc., for the packagecomponents. Consider any damage to the package either from interpretation of the analysis orfrom test observation. This assessment should include structural damage, breach ofcontainment, and loss of shielding.

3.5.4 Accident Conditions for Fissile Material Packages for Air TransportIf applicable, address the expanded fire test conditions specified in 10 CFR 71.55(f).

3.6 APPENDIX

The appendix should include information such as justification of assumption or analyticalprocedures, test results, photographs, computer program descriptions and input and output files,specifications of O-rings and other components, and applicable pages from referenceddocuments.

4. CONTAINMENT

This section of the application should identify and discuss the package containmentsystem and describe how the package complies with the performance requirements of 10 CFRPart 71.

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4.1 DESCRIPTION OF THE CONTAINMENT SYSTEM

4.1.1 Containment BoundaryDefine and describe the containment system, including components such as the

containment vessel, welds, seals, lids, cover plates, valves, and other closure devices. Thedescription should include materials of construction and applicable codes and standards. Identifythe containment boundary of the package.

Describe the containment penetrations and their method of closure. Identify performancespecifications for components such as valves and pressure relief devices. Show that thepackage does not allow continuous venting. Identify the method used to protect any valve orsimilar device on the package against unauthorized operation and, except for a pressure reliefvalve, describe the enclosure used to retain any leakage.

Show that the containment system can be securely closed with a positive fastening devicethat cannot be opened unintentionally or by a pressure that may arise within the package.

4.1.2 Special Requirements for PlutoniumPlutonium in excess of 0.74 Tbq (20 Ci) is required to be shipped as a solid.

4.2 GENERAL CONSIDERATIONS

4.2.1 Type A Fissile PackagesFor Type A fissile packages, no loss or dispersal of radioactive material is permitted

under normal conditions of transport, as specified in 10 CFR 71.43(f). Although 10 CFR Part 71does not provide numerical release limits for Type A packages, the package must retain fissilecontents to ensure subcriticality under both normal conditions of transport and hypotheticalaccident conditions.

4.2.2 Type B PackagesType B packages must satisfy the quantified release rates of 10 CFR 71.51. The

application should describe in detail the method used to demonstrate that these release rates aremet.

4.3 CONTAINMENT UNDER NORMAL CONDITIONS OF TRANSPORT (TYPE BPACKAGES)

The evaluation of the containment system should be performed for the most limitingchemical and physical forms of the contents. Include any significant daughter products. Identify the constituents of the releasable source term, including radioactive gases, liquids, and powderaerosols. Consider the maximum internal pressures.

Demonstrate that the package meets the containment requirements of 10 CFR 71.51(a)(l)under normal conditions of transport. The structural performance of the containment system,including seals, closure bolts, and penetrations, and leakage testing of the containment systemshould be addressed.

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4.4 CONTAINMENT UNDER HYPOTHETICAL ACCIDENT CONDITIONS (TYPE BPACKAGES)

The evaluation of the containment system should be performed for the most limitingchemical and physical forms of the contents. Include any significant daughter products. Identify the constituents of the releasable source term, including radioactive gases, liquids, and powderaerosols. Consider the maximum internal pressures. The releasable contents and internalpressures may be different from those considered under normal conditions of transport.

Demonstrate that the package meets the containment requirements of 10 CFR71.51(a)(2) under hypothetical accident conditions. The structural performance of thecontainment system, including seals, closure bolts, and penetrations, and leakage testing of thecontainment system should be addressed.

4.5 LEAKAGE RATE TESTS FOR TYPE B PACKAGES

Describe leakage tests that are used to show that the package meets the containmentrequirements of 10 CFR 71.51. These may include leakage tests of test units, newly fabricatedpackagings, periodic tests, and pre-shipment tests.

4.6 APPENDIX

The appendix should include supporting information and analysis, including a list ofreferences, copies of applicable references if not generally available to the reviewer, test results,and other appropriate supplemental information.

5. SHIELDING EVALUATION

This section of the application should identify, describe, discuss, and analyze the principalshielding design of the packaging, components, and systems important to safety and describehow the package complies with the performance requirements of 10 CFR Part 71.

5.1 DESCRIPTION OF SHIELDING DESIGN

5.1.1 Design FeaturesDescribe the radiation shielding design features of the package, including dimensions,

tolerances, materials of construction, and densities of material for neutron and gamma shielding.

5.1.2 Summary Table of Maximum Radiation LevelsPresent the maximum dose rates for both normal conditions of transport and hypothetical

accident conditions at the appropriate locations for non-exclusive or exclusive use (or both), asapplicable. See Table 5-1.

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Table 5-1 Example for Summary Table of External Radiation Levels (Non-ExclusiveUse)

Normal Conditions ofTransport

Package Surface mSv/h (mrem/h)

1 Meter from Package SurfacemSv/h (mrem/h)

Radiation Top Side Bottom Top Side Bottom

Gamma

Neutron

Total

10 CFR 71.47(a) Limit 2 (200) 2 (200) 2 (200) 0.1(10)* 0.1 (10)* 0.1 (10)*

* Transport index may not exceed 10.

HypotheticalAccident Conditions

1 Meter from Package Surface mSv/h (mrem/h)

Radiation Top Side Bottom

Gamma

Neutron

Total

10 CFR 71.51(a)(2)Limit

10 (1000) 10 (1000) 10 (1000)

5.2 SOURCE SPECIFICATION

In this section, describe the contents and the gamma and neutron source terms used inthe shielding analysis. Address any increase in source terms with time. For packages designedfor spent fuel transport, assumed fuel burnup, power density, and cooling times should be stated.

5.2.1 Gamma SourceState the quantity of radioactive material included as contents and tabulate the gamma

decay source strength (MeV/sec and photons/sec) as a function of photon energy. Describe indetail the method used to determine the gamma source strength and distribution.

5.2.2 Neutron SourceState the quantity of radioactive material included as contents and tabulate the neutron

source strength (neutron/sec) as a function of energy. Describe in detail the method used todetermine the neutron source strength and distribution.

5.3 SHIELDING MODEL

5.3.1 Configuration of Source and ShieldingDescribe in detail the model that was used in the shielding evaluation. Evaluate the

effects of the tests for normal conditions of transport and hypothetical accident conditions on the

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packaging and its contents. The models used in the shielding calculation should be consistentwith these effects.

Include sketches, to scale, and dimensions of the radial and axial shielding materials. Include the dimensions of the transport vehicle and package location for exclusive-use shipmentsin which the analysis is based on the radiation levels of 10 CFR 71.47(b), as appropriate.

Include all dose point locations in the shielding model, including all locations prescribed in10 CFR 71.47(a) or 71.47(b) and 10 CFR 71.5 l(a)(2). Choose these points to identify thelocation of the maximum radiation levels. Include voids, streaming paths, and irregulargeometries in the model or otherwise treat in an adequate manner.

5.3.2 Material PropertiesDescribe the material properties (e.g., mass densities and atom densities) in the shielding

models of the packaging and contents. The source of the data for uncommon materials shouldbe referenced. Include any changes resulting under normal conditions of transport orhypothetical accident conditions, as appropriate.

5.4 SHIELDING EVALUATION

5.4.1 MethodsProvide a general description of the basic method used to determine the gamma and

neutron dose rates at the selected points outside the package for both the normal and accidentconditions of transport. This should include a description of the spatial source distribution andany computer program used with its referenced documentation. The basic input parametersshould be discussed in detail. The basis for selecting the program, attenuation and removalcross-sections, and buildup factors should be provided.

5.4.2 Input and Output DataIdentify the key input data for the shielding calculations. These depend on the type of

code (e.g., deterministic or Monte Carlo), as well as the code itself. Show that information fromthe shielding models is properly input into the code. Include at least one representative input fileand output file (or key sections of the file). Show that the code achieved proper convergenceand calculate dose rates. Show that the results agree with those reported in the text.

5.4.3 Flux-to-Dose-Rate ConversionInclude a tabulation of the flux-to-dose-rate conversion factors as a function of energy.

Data should be supported by appropriate references.

5.4.4 External Radiation LevelsDescribe the results of the radiation analysis. These should agree with the summary

tables. Select locations of maximum dose rates for the analysis and provide sufficient data toshow that the radiation levels are reasonable and their variations with location are consistent withthe geometry and shielding characteristics of the package. Provide information for normal andaccident conditions.

5.5 APPENDIX

Include information such as justification of assumptions or analytical procedures, testresults, photographs, computer program descriptions and input and output files, references,applicable pages from referenced documents, and other supplemental information.

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6. CRITICALITY EVALUATION

This section of the application should identify, describe, discuss, and analyze the principalcriticality engineering-physics design of the packaging, components, and systems important tosafety and describe how the package complies with the performance requirements of 10 CFR71.55 and 71.59.

6.1 DESCRIPTION OF CRITICALITY DESIGN

6.1.1 Design FeaturesDescribe the design features of the package that are important for criticality. These

should include such information as the confinement system for the fissile material, neutronabsorbing and moderating materials, flux traps, spacers, etc.

6.1.2 Summary Table of Criticality EvaluationProvide a summary table of criticality analysis results for the package for the following

cases, as described in Sections 6.4, 6.5, and 6.6:

• A single package, under the conditions of 10 CFR 71.55(b), (d), and (e)• An array of undamaged packages, under the conditions of 10 CFR 71.59(a)(1)• An array of damaged packages, under the conditions of 10 CFR 71.59(a)(2).

In the table, include the maximum value of the effective neutron multiplication factor (keff), theuncertainty, the bias, and the number of packages evaluated in the arrays.

6.1.3 Criticality Safety IndexProvide the Criticality Safety Index (CSI) based on the number of packages evaluated in

the arrays, and show how it was calculated.

6.2 FISSILE MATERIAL CONTENTS

Provide a description of the fissile materials in the package. Include mass, dimensions,enrichment, physical and chemical composition, density, moisture, and other characteristicsdependent on the specific contents.

6.3 GENERAL CONSIDERATIONS

The considerations discussed below are applicable to the criticality evaluations of a singlepackage and arrays of packages under normal conditions of transport and hypothetical accidentconditions.

6.3.1 Model ConfigurationDescribe and provide sketches of the calculation model used in the calculations. The

sketches should identify the materials used in all regions of the model. Differences between theactual package configuration and the model should be identified, and the model should be shownto be conservative. Differences between the models for the normal conditions of transport andaccident conditions should be clearly identified.

6.3.2 Material PropertiesProvide the appropriate mass densities and atomic number densities for materials used in

the models of the packaging and contents. Material properties should be consistent with the

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condition of the package under the tests of 10 CFR 71.71 and 71.73. Address any differencesbetween normal conditions of transport and hypothetical accident conditions. Specificallyaddress materials relevant to the criticality design such as poisons, foams, plastics, and otherhydrocarbons.

6.3.3 Computer Codes and Cross-Section LibrariesProvide a complete description of the basic calculational methods used to calculate the

effective multiplication constant of the package to demonstrate compliance with the fissilematerial package standards. This should include a description of the computer program andneutron cross-sections used with their referenced documentation. The basis for selecting theprogram and cross-sections should be discussed. Identify key input data for the criticalitycalculations, such as neutrons per generation, number of generations, convergence criteria,mesh selection, etc., depending on the code used.

6.3.4 Demonstration of Maximum ReactivityThe analyses should demonstrate the most reactive configuration of each case listed in

Sections 6.4, 6.5, and 6.6 (single package, arrays of undamaged packages, and arrays ofdamaged packages). Clearly identify and justify assumptions and approximations.

The analysis should determine the optimum combination of internal moderation (within thepackage) and interspersed moderation (between packages), as applicable. Consider thepreferential flooding of different regions within the package as appropriate. Note that themaximum allowable fissile material mass is not necessarily the most reactive contents.

6.4 SINGLE PACKAGE EVALUATION

6.4.1 ConfigurationDemonstrate that a single package is subcritical under both normal conditions of transport

and hypothetical accident conditions. Consider:

• Fissile material in its most reactive credible configuration consistent with thecondition of the package and the chemical and physical form of the contents.

• Water moderation to the most reactive credible extent, including water inleakageto the containment system as specified in 10 CFR 71.55(b).

• Full water reflection on all sides of the containment system as specified in 10 CFR71.55(b)(3), or reflection by the package materials, whichever results in themaximum reactivity.

6.4.2 ResultsThe package should also meet the additional specifications of 10 CFR 71.55(d)(2) through

71.55(d)(4) under normal conditions of transport.

6.5 EVALUATION OF PACKAGE ARRAYS UNDER NORMAL CONDITIONS OFTRANSPORT

6.5.1 ConfigurationAn array of 5N packages should be subcritical under normal conditions of transport.

Consider:

• The most reactive configuration of the array (e.g., pitch and package orientation)with nothing between the packages,

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• The most reactive credible configuration of the packaging and its contents undernormal conditions of transport. If the water spray test has demonstrated that waterwould not leak into the package, water inleakage need not be assumed,

• Full water reflection on all sides of a finite array.

6.5.2 ResultsPresent the results of the analyses for arrays and identify the most reactive array conditions.

6.6 PACKAGE ARRAYS UNDER HYPOTHETICAL ACCIDENT CONDITIONS

6.6.1 ConfigurationAn array of 2N packages should be subcritical under hypothetical accident conditions.

Consider:

• The most reactive configuration of the array (e.g., pitch, package orientation, andinternal moderation),

• Optimum interspersed hydrogenous moderation,• The most reactive credible configuration of the packaging and its contents under

hypothetical accident conditions, including inleakage of water,• Full water reflection on all sides of a finite array.

6.6.2 ResultsPresent the results of the analyses for arrays and identify the most reactive array

conditions.

6.7 FISSILE MATERIAL PACKAGES FOR AIR TRANSPORT

6.7.1 ConfigurationA single package should be subcritical under the expanded accident conditions specified

in 10 CFR 71.55(f). Consider:

• The most reactive configuration of the contents and packaging under theexpanded accident conditions,

• Full water reflection,• No water inleakage.

6.7.2 ResultsPresent the results of the analyses for the single package and identify the most reactive

contents and packaging conditions.

6.8 BENCHMARK EVALUATIONS

Benchmark the computer codes for criticality calculations against critical experiments. Use the same computer code, hardware, and cross-section library as those used to calculate theeffective multiplication factor values for the package in the benchmark experiments.

Provide a justification for the validity of the calculational method and neutron cross-sectionvalues used in the analysis by presenting the results of calculations for selected criticalbenchmark experiments.

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6.8.1 Applicability of Benchmark ExperimentsProvide a description of selected critical benchmark experiments that are to be analyzed

using the method and cross-sections given in Section 6.3. The applicability of the benchmarks inrelation to the package and its contents should be shown. All similarities and differences shouldbe noted and resolved respectively. References giving full documentation on these experimentsshould be provided. Address the overall quality of the benchmark experiments and theuncertainties in experimental data.

Actual nuclear and geometric input parameters used for benchmark calculations shouldbe provided. Provide the results of the benchmark calculations.

6.8.2 Bias DeterminationPresent the results of the calculations for the benchmark experiments and the method

used to account for biases, including the contribution from uncertainties in experimental data.

Analyze a sufficient number of appropriate benchmark experiments and use the results ofthese benchmark calculations to determine an appropriate bias for the package calculations,considering parameters such as pitch-to-rod diameter, assembly separation, neutron absorbermaterial, etc. Address statistical and convergence uncertainties.

6.9 APPENDIX

This appendix should include information such as justification of assumption or analyticalprocedures, test results, photographs, and a list of references and applicable pages fromreferenced documents, if not generally available, and other supplemental information. Includecomputer code descriptions and input and output files. Input files for representative or mostlimiting cases for a single package and arrays of damaged and undamaged packages should beincluded.

7. PACKAGE OPERATIONS

Describe the package operations used to load a package and prepare it for transport. The operations steps should be presented sequentially in the actual order of performance. Theoperations should describe the fundamental steps needed to assure that the package is properlyprepared for transport consistent with the package evaluation in Sections 2 through 6 of theapplication.

The package should be operated in accordance with detailed written procedures that arebased on and consistent with the operations described in this section of the application. Thepackage operations should be consistent with maintaining occupational radiation exposures aslow as reasonably achievable (ALARA) as required by 10 CFR 20.1101(b) of 10 CFR Part 20,“Standards for Protection Against Radiation.”

7.1 PACKAGE LOADING

The operations should include inspections, tests, and preparations of the package forloading. This should include the inspections made prior to loading the package to determine thatthe package is not damaged and radiation and surface contamination levels are within allowablelimits of the regulations.

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7.1.1 Preparation for LoadingAt a minimum, the operations for preparing the package for loading should specify that

the package is loaded and closed in accordance with detailed written procedures, that thecontents are authorized in the package approval, that the package is in unimpaired physicalcondition, that any required moderator or neutron absorber is present and in proper condition. Special controls and precautions for handling should be included. The operations should discussthe inspection of gaskets, criteria for replacement, and if applicable, processes for repair. Theinspection of each closure device and criteria for replacement should also be discussed.

7.1.2 Loading of ContentsAt a minimum, the operations for loading the contents should describe how the contents

are loaded and how the package is closed.

7.1.3 Preparation for TransportThe operations for preparing the package for transport should address radiation and

contamination surveys of the package, leakage testing of the package, measurement of thepackage surface temperature, package tie-down, and the application of tamper-indicatingdevices.

7.2 PACKAGE UNLOADING

This section should include inspections, tests, and special preparations of the package forunloading. As applicable, the operations used to ensure safe removal of fission gases,contaminated coolant, and solid contaminants should be discussed.

7.2.1 Receipt of Package from CarrierThe process for receiving the package should address radiation and contamination

surveys and inspection of the tamper-indicating device. Describe any proposed special controlsand precautions for handling and unloading. Address the appropriate requirements of 10 CFR20.1906, “Procedures for Receiving and Opening Packages.”

7.2.2 Removal of ContentsOperations should include the appropriate method for opening and removing contents

from the package.

7.3 PREPARATION OF EMPTY PACKAGE FOR TRANSPORT

Describe the inspections, tests, and special preparations of the packaging necessary toensure that the packaging is verified to be empty and is properly closed, and the radiation andcontamination levels are within allowable limits. Address the appropriate requirements of 49 CFR173.428 (Empty Class 7 (radioactive) materials packaging).

7.4 OTHER OPERATIONS

Include the provisions for any special operational controls (e.g., route, weather, shippingtime restrictions, etc.).

7.5 APPENDIX

This appendix should include supporting documentation, detailed discussions andanalysis of processes or protocols, and graphic presentations. Include a list of references, copies

29

of applicable references if not generally available, test results, and other appropriatesupplemental information.

8. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM

This section of the application should discuss the acceptance tests and maintenanceprogram to be used for the packaging in compliance with Subpart G of 10 CFR Part 71.

8.1 ACCEPTANCE TESTS

Discuss the tests to be performed prior to the first use of each packaging. Theinformation should include a description of the test and its acceptance criteria. The acceptancetests must confirm that each packaging is fabricated in accordance with the drawings referencedin the package approval.

8.1.1 Visual Inspections and MeasurementsThe visual inspections to be performed and the intended purpose behind each inspection

should be discussed. State the criteria for acceptance of each of these inspections as well as theaction to be taken if noncompliance is encountered. The inspections should verify that thepackaging has been fabricated and assembled in accordance with the drawings. Dimensions andtolerances specified on the drawings should be confirmed by measurement.

8.1.2 Weld ExaminationsDescribe welding examinations to verify fabrication in accordance with the drawings,

codes, and standards specified in the application. Location, type, and size of the welds should beconfirmed by measurement. Other specifications for weld performance, nondestructiveexamination, and acceptance should be verified as appropriate.

8.1.3 Structural and Pressure TestsIdentify and describe the structural or pressure tests. Such tests should comply with

10 CFR 71.85(b), as well as applicable codes or standards specified. Describe the action takenwhen the prescribed criteria are not met. An estimate of the sensitivity of the tests should beprovided.

8.1.4 Leakage TestsDescribe the leak tests to be performed. Leak tests should be performed on the

containment vessel as well as on auxiliary equipment. Describe the criteria for acceptance andthe action to be taken if the criteria are not met. Specify the sensitivity of the test and give thebasis for the estimate.

8.1.5 Component and Material TestsSpecify the appropriate tests and acceptance criteria for components that affect package

performance. Provide acceptance criteria and discuss the action to be taken if the criteria are notmet. Specify test sensitivity, as applicable.

Specify the appropriate tests and acceptance criteria for packaging materials. Components such as gaskets should be tested under conditions simulating the most severeservice conditions under which the gaskets are to perform, including performance at pressureand at high and low temperatures. Tests for neutron absorbers (e.g., boron) and insulatingmaterials (e.g., foams, fiberboard) should assure that minimum specifications for density and

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isotopic content are achieved. Test the materials to meet the performance specifications shownon the engineering drawings.

8.1.6 Shielding TestsSpecify the appropriate shielding tests for both neutron and gamma radiation. The tests

and acceptance criteria should be sufficient to assure that no defects, voids, or streaming pathsexist in the shielding.

8.1.7 Thermal TestsSpecify the appropriate tests to demonstrate the heat transfer capability of the packaging.

These tests should confirm that the heat transfer performance determined in the thermalevaluation is achieved in the fabrication process.

8.1.8 Miscellaneous TestsDescribe any additional tests to be performed prior to use of the packaging.

8.2 MAINTENANCE PROGRAM

Describe the maintenance program used to ensure continued performance of thepackaging. The program should include periodic testing, inspection, and replacement schedules,as well as criteria for replacement and repair of components and subsystems on an as-neededbasis.

8.2.1 Structural and Pressure TestsIdentify and describe any periodic structural or pressure tests. Such tests would generally

be applicable to codes, standards, or other procedures specified in the application.

8.2.2 Leakage TestsDescribe the tests to be performed and the frequency of performance. Specify the

sensitivity of these tests. For most systems, this would include a test of each package beforeeach shipment and an annual test of each packaging. In general, elastomeric seals are replacedand leak tested within the 12-month period prior to shipment. Metallic seals are generallyreplaced and tested prior to each shipment.

8.2.3 Component and Material TestsDescribe, as appropriate, the periodic tests and replacement schedules for components.

Identify any process that could result in deterioration of packaging materials, including loss ofneutron absorbers, reduction in hydrogen content of shields, and density changes of insulatingmaterials. Ensure packaging effectiveness for each shipment through the appropriate tests andacceptance criteria. Specify replacement intervals for components susceptible to fatigue, such asbolts.

8.2.4 Thermal TestsDescribe the periodic tests to assure the heat-transfer capability during the service life of

the packaging. Tests similar to the acceptance tests discussed in Section 8.1.7 may beapplicable. The typical interval for periodic thermal tests is 5 years.

8.2.5 Miscellaneous TestsDescribe any additional tests to be performed periodically on the package or its

components.

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8.3 APPENDIX

Include a list of references, copies of applicable references if not generally available, andother appropriate supplemental information.

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DRAFT VALUE/IMPACT STATEMENT

A separate regulatory analysis was not prepared for this regulatory guide. Revision of thisregulatory guide was necessary to make the guide consistent with the 10 CFR Part 71 final rulethat brings Part 71 into harmony with the 1996 Edition of the International Atomic Energy AgencyRegulations for Safe Transport of Radioactive Material (TS-R-1). NUREG/CR-6713, “DraftRegulatory Analysis of Major Revision of 10 CFR Part 71," provides the regulatory analysis forthis regulatory guide. A copy of NUREG/CR-6713 is available for inspection and copying for afee at the U.S. Nuclear Regulatory Commission Public Document Room, 11555 Rockville Pike,Rockville, MD; the PDR’s mailing address is USNRC PDR, Washington, DC 20555; telephone(301)415-4737 or (800)397-4209; fax (301)415-3548; e-mail <PDR@NRC.GOV>. Copies areavailable at current rates from the U.S. Government Printing Office, P.O. Box 37082,Washington, DC 20402-9328 (telephone (202)512-1800); or from the National TechnicalInformation Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161;<http://www.ntis.gov/ordernow>; telephone (703)487-4650.